Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Benefit under the SHIS Scheme (Status Holder Incentive Scheme) - Import of Turning Cradle and Blade Shell Lifting Device - Goods were considered as not falling within the category of "relating to plastic sector" - The Customs department initially accepted the goods as used but later contradicted this finding based on revised reports from Shri N J Lalwani. (Valuer) - The Tribunal found merit in the impugned order, stating that all necessary documents were provided to the appellant for cross-examination. - However, in the interest of justice, the Tribunal allowed one last opportunity for the appellant to cross-examine Government approved valuer and remanded the matter back to the Commissioner for fresh adjudication.
Benefit under the SHIS Scheme (Status Holder Incentive Scheme) - Import of Turning Cradle and Blade Shell Lifting Device - Goods were considered as not falling within the category of "relating to plastic sector" - The Customs department initially accepted the goods as used but later contradicted this finding based on revised reports from Shri N J Lalwani. (Valuer) - The Tribunal found merit in the impugned order, stating that all necessary documents were provided to the appellant for cross-examination. - However, in the interest of justice, the Tribunal allowed one last opportunity for the appellant to cross-examine Government approved valuer and remanded the matter back to the Commissioner for fresh adjudication.
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